Figure 1: Illustrates a "safe" set-up for Cold Work where PPE is required.

The OSHA Hierarchy of Controls

Engineering Controls

Administration Controls

Personal Protective Equipment (PPE)

Cleaning and other cold work requires pre-planning and evaluation of the area/space for potential hazards before work is begun. Usually a Shipyard Competent Person (SCP), Certified Industrial Hygienist (CIH), or Certified Marine Chemist (CMC) will be needed to assist with the evaluation of hazards and selection of PPE. Additional hazards will exist if work is done in an enclosed or confined space (see confined space).

Cleaning operations present a significant risk for skin, eye, and respiratory exposure to toxic and corrosive chemicals in shipyard employment operations. In addition, cleaning operations often require the use of respiratory protection equipment. Employers must comply with 29 CFR 1915.154, which references 29 CFR 1910.134.

Typical cleaning and other cold work cleaning operations are as follows:

Each of these operations may present unique hazards. Therefore a qualified person must select PPE based on the specific cleaning operation. Use of the following appropriate combination of PPE will provide protection:

PPE is required when using corrosive materials and must provide protection from their corrosive effects on the skin, eyes, and respiratory tract of the user. Strong acids and bases (such as hydrochloric acids, lye) are commonly used to remove petroleum residues. In addition to direct contact with these chemicals, reactions between the cleaner and the material being removed may produce toxic, flammable and combustible vapors or liquids. A Shipyard Certified Person (SCP), Certified Industrial Hygienist (CIH) or Certified Marine Chemist (CMC) can determine what PPE is necessary for the specific operation. It is important to have suitable quick emergency eye and body flushing facilities when corrosive cleaners are used. [29 CFR 1910.151(c)]

PPE is required when removing residue by hand such as scraping, shoveling, or wiping. Primary hazards related to manual removal include skin (especially feet) and eye contact with the material or residue being removed.

PPE is required when using water or steam as a cleaner and must protect the worker from eye contact and skin burns. Water and steam can be at a high pressure, which can also cause trauma to the skin or eyes. The PPE should protect the worker from skin contact with the material being removed, which in many cases can be toxic or corrosive. A Shipyard Competent Person (SCP), Certified Industrial Hygienist (CIH) or Chemical Marine Chemist (CMC) can determine what PPE is necessary for the specific operation.

PPE is required when using toxic cleaners (such as Trichloroethane
(TCE) and Methyl Ethyl Ketone (MEK)) and must provide protection from exposure to
the liquid, vapors, or mists that present inhalation, skin contact, or
absorption hazards. Care should be taken in the selection of the protective
clothing fabric to ensure protection against the solvents. Reactions between the
cleaner and the material being removed may produce additional toxic vapors or
liquids. A Shipyard Competent Person (SCP), Certified Industrial Hygienist (CIH) or Certified Marine Chemist
(CMC) can determine what PPE is necessary for the specific
operation.